Supreme Court Refuses Extension for PG Medical Admissions: Education Promotion Society vs. Union of India (21 June 2019)

Date of the Judgment: 21 June 2019
Citation: Not Available
Judges: Deepak Gupta, J., Surya Kant, J.
Can medical colleges be granted an extension of time to fill vacant postgraduate (PG) seats? The Supreme Court of India recently addressed this question, refusing to grant a general extension for PG medical admissions. The Court emphasized the importance of adhering to the admission schedule to maintain the integrity of the process. This judgment was delivered by a bench of Justices Deepak Gupta and Surya Kant.

Case Background

The Education Promotion Society for India, representing various educational institutions including medical colleges, filed a writ petition seeking an extension of time for PG medical admissions. The petitioners argued that many seats were vacant and that medical colleges had invested heavily in infrastructure. They also highlighted the shortage of doctors in India. The Union of India opposed the petition, emphasizing the need to maintain the admission schedule previously set by the Court.

Timeline

Course of Proceedings

The petitioners sought an extension of time for medical colleges to conduct counselling for PG courses, citing a large number of vacant seats. The Union of India opposed this, arguing that it would undermine previous Supreme Court orders that mandated a strict admission schedule. The Court had previously established this schedule to prevent irregularities in admissions and ensure a fair process.

Legal Framework

The Supreme Court referred to previous orders in Mridul Dhar vs. Union of India, Priya Gupta vs. State of Chhattisgarh, and Ashish Ranjan vs. Union of India. These cases established the importance of adhering to the admission schedule set by the Medical Council of India. The schedule includes deadlines for result declarations, counseling rounds, and the last date of joining. The Court emphasized that these schedules were put in place to prevent private medical colleges from exploiting the system by admitting undeserving students and charging high fees.

Arguments

Arguments by the Petitioners:

• The petitioners, representing medical colleges, argued that they had invested heavily in infrastructure.
• They contended that there is a shortage of doctors in India.
• They pointed out that the Union of India had allowed an increase in seats in government medical colleges without a corresponding increase in infrastructure, suggesting a need for more doctors.
• They relied on previous orders where the Court had granted extensions for admissions in graduate, PG, and super-speciality courses. Specifically, they cited an order dated 11.10.2017, where the Court allowed mop-up counselling for unfilled super-speciality seats.
• They requested a similar order to allow them to fill vacant PG seats.

Arguments by the Union of India:

• The Union of India opposed the petition, arguing that granting an extension would undermine the sanctity of previous Supreme Court orders in Mridul Dhar, Priya Gupta, and Ashish Ranjan cases.
• They emphasized that these orders mandated strict adherence to the admission schedule to prevent irregularities in admissions.

Issues Framed by the Supreme Court

The primary issue before the Supreme Court was whether to grant an extension of time to medical colleges for conducting counseling for PG courses, given the number of vacant seats, despite the previously established admission schedule.

Treatment of the Issue by the Court

Authorities

Cases Relied Upon by the Court:

• Mridul Dhar vs. Union of India: The Supreme Court noted that this case highlighted the lack of consistency in admission schedules and how private colleges exploited these discrepancies. The Court directed strict adherence to the schedules notified by the Medical Council of India.
• Priya Gupta vs. State of Chhattisgarh: This case reiterated the importance of adhering to the admission schedule.
• Ashish Ranjan vs. Union of India: The Supreme Court specifically approved the time schedule for medical admissions in this case.

Orders Relied Upon by the Petitioners:

• Order dated 11.10.2017 in M.A. No.1043 of 2017 in I.A.No.96448 of 2017 in W.P.(C) No.743 of 2017: This order, passed on the request of the Central Government, allowed mop-up counselling for 553 unfilled super-speciality seats. The Court clarified that this order was specific to that academic year.

Judgment

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the need to maintain the integrity of the admission process for medical courses. The Court emphasized that allowing extensions would defeat the purpose of having a fixed schedule, which was established to prevent irregularities and ensure fairness. The Court also noted that while many seats were vacant, a significant portion of these were in non-clinical subjects, which do not attract as many candidates. The Court was not persuaded by the petitioners’ arguments regarding infrastructure investments or the shortage of doctors, as these did not justify violating the established schedule.

The Court’s reasoning was as follows:

• The Court emphasized the need to maintain the sanctity of the admission schedule to prevent irregularities.
• The Court noted that previous orders had clearly established the importance of adhering to the schedule.
• The Court observed that most of the vacant seats were in non-clinical subjects, indicating a lack of interest among candidates rather than a systemic issue.
• The Court held that granting extensions would undermine the entire purpose of having a fixed time schedule.

The Court stated, “If we permit violation of schedule and grant extension, we shall be opening a Pandora’s box and the whole purpose of fixing a time schedule and laying down a regime which strictly adheres to time schedule will be defeated.”

The Court also clarified, “Merely because the seats are lying vacant, in our view, is not a ground to grant extension of time and grant further opportunity to fill up vacant seats. The schedule must be followed.”

The Court further noted, “Except the orders in M.A. No.1043 of 2017 in I.A.No.96448 of 2017 in W.P.(C) No.743 of 2017, all the orders are either state specific or college/university specific. They have been passed in the peculiar facts and circumstances of each particular case and in most of the orders it is clearly mentioned that the orders shall not be treated as precedent.”

Key Takeaways

• The Supreme Court has emphasized the importance of adhering to the admission schedule for medical courses.
• Medical colleges cannot expect extensions of time for admissions simply because seats remain vacant.
• The Court’s focus is on maintaining the integrity of the admission process and preventing exploitation by private colleges.
• The Court is unlikely to grant general extensions unless there are extraordinary circumstances.

Directions

No specific directions were given by the Supreme Court in this judgment.

Development of Law

The ratio decidendi of this case is that the admission schedule for medical courses must be strictly adhered to, and extensions will not be granted simply because seats remain vacant. This case reinforces the Supreme Court’s previous stance on maintaining the integrity of the admission process and preventing irregularities. There is no change in the previous position of law; rather, this case reiterates the previous position.

Conclusion

The Supreme Court dismissed the writ petition filed by the Education Promotion Society for India, refusing to grant a general extension of time for PG medical admissions. The Court emphasized the importance of adhering to the established admission schedule to maintain the integrity of the process and prevent exploitation by private medical colleges. The judgment reinforces the need for strict compliance with the timelines set by the Medical Council of India.